On 22nd May, OFAC announced new Ukraine-/Russia-related  General License 15 that authorises US persons to engage in specified transactions related to winding down or maintaining business with GAZ Group and its subsidiaries until October 23rd; and Ukraine-/Russia-related General License 12C, which replaces and supersedes General License 12B in its entirety, and permits originating and intermediary US financial institutions to process funds transfers that they would otherwise block to an account held by a blocked US person at a US financial institution and clarifies that US financial institutions can release such funds for authorised maintenance and wind-down purposes.  Although under General License 15 all funds blocked prior to 12:01 a.m. EDT on May 22nd, remain blocked, the licence authorises the use of these blocked funds for the maintenance and wind down activities described in the licence. OFAC has also published 6 new FAQ and revised existing FAQ to include mention of the licences.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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